Jimmy A. and Cindy R. Lobe - Page 3




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            signatory authority, and they received nonemployee compensation                            
            of $2,319 from a State bank (Bank).  Ms. Lobe received during                              
            that year $1,544 in wages.  Mr. Lobe received during 1996 $700 in                          
            nonemployee compensation from the CU.                                                      
                  During 1995 and 1996, petitioners conducted a business known                         
            as Jim Lobe Construction (JLC).  They reported to the State of                             
            Washington that JLC’s gross receipts in the respective years were                          
            $128,464 and $85,184.  They have not provided to respondent or to                          
            the Court any documentation to substantiate any costs of goods                             
            sold or business expenses which they may have incurred during                              
            those years in JLC’s operation.  Nor have they provided any                                
            documentation to substantiate their entitlement to any other                               
            deduction for those years.                                                                 
                  Respondent determined that Mr. Lobe had failed to report                             
            taxable income of $122,251 and $74,946 during the respective                               
            years.  Respondent determined this income as follows, noting that                          
            because Washington is a community property State, respondent was                           
            treating Mr. Lobe as realizing all of his income and 50 percent                            
            of Ms. Lobe’s income:1                                                                     




                  1 Respondent concedes on brief that each spouse should be                            
            taxed on only 50 percent of the income that he or she earned and                           
            that a computation under Rule 155 will be necessary to effect                              
            this result.  Respondent determined in the notices of deficiency                           
            as a protective measure that each spouse was taxable on 100                                
            percent of the income that he or she earned.                                               





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